General Insurance Privacy Notice
This is the privacy notice of Castle Sundborn Ltd (registration number: 818135) whose registered office is at: The Old Bank, 10 High Street, Malmesbury, Wiltshire, SN16 0DT and referred to as we, us or our in this privacy notice.
This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
This privacy notice may vary from time to time so please check it regularly. This privacy notice was last updated on 16th April 2018.
How to contact us
Controller and contact details
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.
Our data protection representative is Anthony Bather who you can contact via the above address,
Tel: 01666 825200, Fax: 01666 825782 or email: email@example.com
What information we hold about you and where we obtain this from
The personal data that we collect about you may include the following information:
- Personal data you provide to us in person, via our website or by telephone
- Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what and/or who you want to insure, such as vehicle details, business activities, your home or travel details
- General information about you, such as your name, address, contact details and date of birth
- Personal data you provide if you subscribe to any of our mailing or newsletter services
- Your claims and credit history
- Financial details, such as your bank account and card details
- Criminal convictions
- Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this privacy notice specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.
We collect your personal data from you as a controller when we obtain quotations for insurance for you, when we set up your policy for you and when we make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging insurance for them under your policy such as named driver, employee or travel companion etc. you confirm that you have their permission to do so and that you have shared this privacy notice with them.
By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.
We also collect information from publically available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
How we use your personal data and the lawful basis for doing so
Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
|Purposes for which we process your personal data||The basis on which we can do this (this is what the law allows)|
|In order to perform our contractual obligations to you. This would include our fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals)||The processing is necessary in connection with any contract that you may enter into with us|
|To administer your account, including financial transactions for insurance broking||The processing is necessary in connection with any contract that you may enter into with us|
|To assist in the prevention and reduction of fraud and other financial crime||The processing is necessary for us to comply with the law and our legal requirements|
|In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded||The processing is necessary to pursue our legitimate interest in the management and operation of our business|
|To let you know about similar products and services that may be of interest to you||The processing is necessary to pursue our legitimate interest in operating our business|
Special categories of data and criminal convictions
We may also need to collect special categories of data from you, such as information about health, in order to perform our contractual obligations to you. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance. We may also collect information on criminal convictions which we may share with third parties. The lawful basis on which we can do this is that the processing is necessary for reasons of substantial public interest relating to insurance.
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
- Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at renewal we will check if any of our associated group companies can provide you with suitable cover
- The insurers, intermediaries and third party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
- Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
- Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
- Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
- Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
- Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
- Third parties we use to recover money you may owe us or to whom we may sell your debt
- Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
Accessing our website and cookies
When you visit one of our websites we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.
Internet browsers normally accept cookies by default, although it's possible to set a browser to reject cookies. We'll ask your permission before using any cookie that's not essential to the email or the use of the website. However, refusing to accept cookies may restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on cookies when you visit our website.
The open nature of the internet is such that data may flow over networks without security measures, and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information. If this is the case, we'll let you know our reasons.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or to object to the use of your personal information at any time
- Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again
If you have any questions or concerns about this privacy notice or your data protection rights please contact us using our details set out at the beginning of this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk
How we contact you about other products and services
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs. This includes keeping you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
Data Protection and Privacy Notice
Financial Planning Services
In order to provide you with financial planning services we will collect and hold personal data about and on you. We are also required to comply with the General Data Protection Regulation (Regulation (EU) 2016/679 (the “GDPR)) and as such hereby set out details as to how we process your data and your rights.
Why we need your data:
We need your data in order for us to:
- Provide financial planning services to you in accordance with this agreement which may include but not limited to giving you financial advice and making recommendations as to investments and financial products which are suitable for you, taking into account current financial markets and economic conditions, availability of products and the providers of those products, as well as a detailed analysis of your personal circumstances and requirements.
- Comply with our regulatory obligations imposed by the Financial Conduct Authority in regard to the relevant ‘Know Your Client’ obligations. In addition, to comply with the Regulator’s requirements for record keeping for the purposes of audits and reviews, records of transactions undertaken and customer histories for prescribed periods of time as directed.
- Respond to any legitimate legal requests for information about you to the Regulatory authority or pursuant to an order of any court or tribunal having relevant jurisdiction, or as required by law for the purposes of but not limited to combatting fraud, money-laundering and criminal activities.
- Carry out our legitimate business and professional management responsibilities which include, but are not limited to providing you with suitable advice, ensuring your portfolio and financial products continue to be suitable for you, adhere to anti money laundering requirements and investigating and resolving complaints.
General information about your data and your rights:
Where we collect data directly from you, we will undertake:
- In addition to those third party companies expressly detailed in this agreement, to inform you in writing of the name and contact details of the data controller for that data and their representative. For example, where we arrange an investment on your behalf with a third party investment provider, the data controller may be the financial institution in question.
- To inform you, where appropriate, of the contact details for any Data Protection Officer appointed by us.
- To inform you and make clear the purposes for which the data is to be processed and the legal basis for that processing. In the event that the legal basis to be relied on is that of the legitimate interests of the data controller or any third party, we will inform you as to the nature of those legitimate interests.
- To inform you of the recipients or categories of recipients of data.
- In the event that the data controller proposes to transfer the data to a country other than those covered by the GDPR, to provide you with details of the safeguards surrounding such transfers and how to obtain a copy of them.
- To inform you of the period for which we propose to hold the data, or where this is not possible, the criteria which we will apply to data retention.
- To remind you of your rights whereby you may:
- Request access to data of which you are the data subject
- Object to, or withdraw consent for, the processing of the same
- Obtain rectification of inaccurate data
- Prevent data processing for the purposes of direct marketing
- Object to decisions being taken by automated means and to have the logic behind those decisions clearly explained
- Claim compensation for damages caused by a breach of the Act
- Request data erasure
Where you exercise your right to request (via email or post) access to data of which you are the data subject, we will undertake to respond to you within 30 calendar days of receipt of your request. There will be no charge for this service unless the request is manifestly unfounded or excessive in which case we reserve the right to charge a fee or refuse to respond.
You may at any time, by giving notice to us in writing, request that we cease to process your data. We will undertake to comply with any such request as soon as is reasonably practicable.
Where the legal basis for the processing of your data is to adhere to compliance with a statutory or contractual obligation, or the necessary precondition to entering into a contract, including compliance with the requirements of any Regulator, we will inform you as to:
- Whether you are legally required to provide such data, and
- The consequences of failing to provide such data
Where we obtain your data otherwise than directly from you, you will have the same or equivalent rights to those set out above.
Save in the circumstance as detailed below, we will inform you which source the data originated from and whether it came from publically accessible sources. The information to be provided will be in accordance with the following time periods, whichever shall occur first:
- As soon as practicable after obtaining the data and in any event within 1 month
- At the time of our first communication with you using the data
- When the data is first disclosed to another person
We shall not be obliged to provide you with the information:
- Where you already have this information
- Where we are subject to an obligation of professional secrecy prohibiting the disclosure of the information
- Where disclosure would render impossible or severely impair the achievement of the reasons for which the data is to be processed. In such cases, we will do what we can to protect your rights and freedoms with respect to our processing of the data
You have the right to complain in regard to any aspect of the processing of your data and any breach of the above rights to the relevant supervisory authority, who in the case of the United Kingdom is the Information Commissioners Office, whom may be contacted at:
- Online: www.ico.org.uk
- Phone: 0303 123 1113
Holding your data:
We undertake to review the data we hold on you on a regular basis to ensure compliance with data protection law. In the course of any review, we will:
- Delete any data which is trivial or transitory in nature, or which in our opinion is no longer required for the purposes set out above.
- Update the data to ensure that any errors or inaccuracies are corrected.
- Archive data as detailed below.
- Subject to the data retention periods, as detailed below, securely delete the data when it is identified that we no longer need to hold it.
We may retain and process your data for the following periods. In the event that more than one period applies to the same data, we will retain the data to the last such period to expire:
- We will hold any agreements between you and us for a period of 125 years from the termination or expiry of the agreement unless we have been notified of any claim or circumstance which might give rise to a claim under or by reference to such agreements, this period falls in line with the maximum lifespan of a Trust.
- We will process data relating to investments which we have provided advice on and / or arranged for you. We will process such data throughout the entire period you are and remain a client of the firm and for a period of not less than 125 years following our ceasing to provide service to you in regard to those investments, again this is in line with the maximum lifespan of a Trust.
- We will hold date as required by any Regulator until the end of any limitation period imposed by that Regulator, which in the case of the Financial Services Authority is currently 6 years for all types of business undertaken except for Occupational Pension Schemes, which can include Defined Benefit Transfers and Scheme Money Purchase Transfers, whereby the data retention period is indefinite.
- We will hold data as required by any relevant third party until the end of any limitation period imposed by that relevant third party, which in the case of HMRC shall be 7 years, unless we are notified that any period is considered “open” by HMRC in which case it will be until we are notified the period is “closed”.
- We will hold data as required for the purposes of any legal proceedings for a period of 125 years following the conclusion of any such proceedings unless a longer period is required pursuant to any court rule or enactment. Proceedings will be taken to have concluded on the expiry of any period given for appealing any final judgment or on the date of concluding any settlement staying all relevant claims if the proceedings were settled before judgement.
- Save for the above, we will hold data for a maximum of 125 years from the date we receive the data.
We will regularly review data and where in our opinion such data has ceased to be Active we will archive it and process it only as Archived Data. Any data which is deemed Archived Data will only be processed in limited circumstances.
All storage of data, whether Active Data or Archived Data will be in accordance with good industry practice and will be undertaken in accordance with organisational systems and procedures, which will be regularly reviewed, to maintain the security of data.
On the termination or expiry of any agreement to provide services to you and on your written request, we will, subject to our right to retain copies of data for the purposes set out above, agree to return any data you have provided to us in a structured, commonly used machine-readable format, or transfer the same to a new data controller nominated by you.
Whom we may share your data with:
In order to carry out our legitimate business and to provide you with financial planning services, we have entered into agreements with and will share your information with the following companies, for the purposes of Compliance, IT systems security, data management and control and auditing. Full details of these companies addresses (all UK based) and contact details are available on request:
- Compliance and Training Solutions Ltd (Compliance consultants)
- Priority IT (IT Consultants)
- Intelliflo (Financial Services Back Office System)
- Open GI (General Insurance Back Office System)
- Broker Network (Compliance Support)
- Greenwood Williams (Accountants)
- Milsted Langdon LLP (Account Auditors)
In addition to the above listed companies you will be notified in accordance with the terms of this agreement as to the name and contact details of the data controller for any other third party entity with whom we share and / or transfer your data and their representative.
From time to time we may wish to contact you with details of other investment, pension or financial products and/or services which we think may be of interest and/or beneficial to you. If you consent to us contacting you for this purpose then please tick the options below in regard to how you would like to be contacted:
Post o Email o Telephone o
If you do not tick any of the above options we will reasonably assume that you do not wish to be contacted by us in regard to additional investment, pension or financial products and services.
We will not use your data for marketing purposes of any sort unless you have expressly given us your prior consent. The use of your data as detailed in the remained of this agreement is not affected by whether you choose to consent to the use of data for marketing purposes.
Please note that you may withdraw your consent to marketing at any time by giving us notice in writing.
If any provision, or part thereof, of this agreement is found by any court or administrative body of competent jurisdiction to be invalid, unenforceable or illegal, the other provisions shall remain in force.
In the event of any change in Data Protection Law occurring after the date of this agreement which requires the adoption of revised provisions dealing with data retention or portability, the parties will use all reasonable endeavours to agree such consequential changes to this agreement as may reasonably be required to comply with the requirements of Data Protection Law (“Compliant Terms”) and incorporate the same as an amendment to this agreement.
Declaration and Consent:
We take your privacy very seriously and will only use your personal information and data to administer the services we have agreed to provide you with, including but not limited to any products or contracts for investments, pensions, life cover, equity release or discretionary investment management services you have made or entered into through our firm. By signing this Data Protection and Privacy Notice you are confirming your agreement to these terms.
By signing this Data Protection and Privacy Notice you are also confirming your marketing preferences as detailed in the ‘Marketing’ section of this agreement whereby you have given your consent, or otherwise, for either us to contact you about additional products and services.
You further acknowledge, by signing this Data Protection and Privacy Notice, that you have been made aware of, and give your consent to, this firm’s policy on sharing your data with other companies as detailed in the ‘Whom we may share your data with’ section of this agreement.
Client Signature: Client Signature:
Client Name: Client Name:
Data Protection Policy
All staff are required to be mindful of the data that they see and how it is used in order to protect the client. Below is a list of basic rules which all staff must adhere to:
Ensure that personal data is accurate, proportionate, up to date and is fit for the purpose it was collected for and only keep it for as long as is necessary.
Ensure that anyone providing personal data understands what the information will be used for. If the data is sensitive (race, sexuality, criminal offences, mental or physical health data) you will normally need to get explicit written consent for its disclosure to a third party - the individual must be informed of the reason why that this type of data is being held (if requested). Some disclosures are exempt from this requirement, such as Police and crime agency information requests
Review data on a regular basis and update it where necessary.
Dispose of manual files that are no longer required or print outs as confidential waste, and check computers do not have personal data on the hard drive before they are decommissioned
Any change of address details must be recorded in writing by the way of email, fax or letter.
A clean desk policy exists, meaning manual files must be securely locked up, not left on desks overnight
A record should be kept of the location of paper files when not in the filing system or taken away from the office.
Ensure that any electronic files holding personal data are password protected and that the password is periodically changed
Be aware that the individual about whom the information relates to, has a right to see all the information that is held about them. Therefore inserting personal remarks or notes on files should always be avoided, this includes emails
Be aware that any breach of the provisions of the Data Protection Act could attract personal criminal liability. This may arise if you knowingly or recklessly, obtain or disclose personal data to another source
If you receive a data subject access request, you must deal with the request promptly, within 40 days.
Have systems in place for vetting new staff/and or third party suppliers (e.g. IT support/cleaners etc.) who will have access to personal data.
Have appropriate controls in place to confirm the identity of any party contacting the firm asking for personal data. E.g. product providers or clients requesting details.
Have regular training/updates for staff in data protection requirements.
Ensure that the firm has written procedures for dealing with subject access requests and data handling.
Use data for a different purpose than that for which it was obtained.
Disclose information to other staff members unless the use of that data is within their authorised duties
Share your passwords with anyone other than your immediate Manager/Julie Curtis or Amy Wilkins.
Leave computers logged on and unattended unless you have a password-protected screensaver
Forget to record the reason for disclosing any personal or sensitive personal data to a third party
Give out personal information over the phone without adequate verification controls or in person without verification of the purposes of any data disclosure.
Include any sensitive personal information in any email message or document unless it is protected (encrypted) and sent via a safe network.
Forward email messages containing personal data without the sender’s consent.
Disclose personal data to a third party without the explicit consent of the data subject (Unless specific exemptions apply).
Keep any inaccurate data on record.
Forget to annually review and update the purposes and activities for which data is held and registered with the Information Commissioner’s Office.
Transfer personal data outside of the EEA, unless equivalent data protection controls exist in the end destination.
As a Financial Services firm authorised with the Financial Conduct Authority (FCA) the regulator has set out its rules in relation to handling clients complaints. In order to meet these rules we have put the following procedures in place.
- On receipt of your complaint we will record receipt of the complaint and write to acknowledge receipt of your complaint within 5 working days, unless it can be resolved within 3 business days. Within the acknowledgement letter we will provide you with a copy of these complaint procedures.
- If your complaint was made verbally, then within our acknowledgement letter we will confirm our understanding of your complaint.
- Your complaint will then be investigated by our Compliance Officer, Anthony Bather, who will gather all documentation required in order to thoroughly and objectively conduct the investigation. This may require some addition information from you and therefore an authority letter may be required so we can approach any 3rd party necessary.
- During the above process we will keep you informed of its progress to date and whether there is any further information we require from you. We will aim to deal with your complaint as quickly as possible.
- If we have not resolved your complaint within 8 weeks from date of receipt, we will write to you again with our reasons for delay however we also enclose the leaflet “Your Complaint and the Ombudsmen” informing you of your rights to take action further to the Financial Ombudsman if you are unhappy with the progress. We will confirm when we expect our final response to be made.
- Within our final response letter we will set out our understanding of your complaint, the issues raised, the investigation we conducted and the outcome from the investigation. We will also detail any redress we believe appropriate or the reasons for declining redress.
- We will endeavour to communicate with you in a clear and fair manner at all times whilst investigating your complaint.
If you are not satisfied with our final response, you have the right to refer your complaint to the Financial Ombudsman Service, free of charge.
The Ombudsman might not be able to consider your complaint if:
- What you're complaining about happened more than six years ago, and
- You're complaining more than three years after you realised (or should have realised) that there was a problem.
- We will tell you if we think that your complaint is made outside of these time limits but this is a matter for the Ombudsman to decide. If the Ombudsman agrees with us, they will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances.
- If you do decide to refer your complaint to the Ombudsman you must do so within six months of our final response letter.
- If you do not refer your complaint to the Ombudsman within six months of the date of this letter, the Ombudsman will not have our permission to consider your complaint ans so will only be able to do so in very limited circumstances.
Client Proposition Professional Financial Advice Services
Our Client Service Proposition aims to introduce you to Castle Sundborn Ltd, our company ethos and the financial advice services we offer.
Thank you for your interest in Castle Sundborn Ltd. Your interest is very much appreciated whether you are a prospective client or one of our many existing clients.
We pride ourselves on making your financial investment’s, pensions and retirement options clear and simple so you can be confident that you are making the right decisions, We aim to add value through the services we provide to all of our clients.
Castle Sundborn Ltd provides a personal service, tailored to meet your needs. We listen and give unbiased advice to help you manage your savings and investments. Our aim is to take the worry out of your finances, allowing you to relax and enjoy life. Our advisers will work with you to help you make the right investment choices both now and in the future.
We are a firm of advisers based in Malmesbury, Wiltshire. We specialise in providing unbiased advice on investments, pensions and retirement options to both individual and corporate clients. This advice is however restricted. We will advise and make a recommendation for you after we have assessed your needs. We only offer advice on limited types of products. You may ask us for a list of the products we offer. As experienced and dedicated financial advisers there are certain types of investment on which we do not advise because of the increased risks attached to such products.
The firm is an established family run practice set up in 1964 by Timothy Bather, the chairman. Anthony Bather joined the firm in 1988 and is now Managing Director. The business continues to thrive, attracting business predominantly through existing client referrals.
Our relationship with you does not stop once you have made an investment. We keep you up to date with the performance of your plans and we stay in touch to ensure that any changes to your lifestyle or financial goals are reflected in your portfolio.
We can provide you with advice in the following areas:
We will establish an investment proposition tailored to your needs and financial objectives. We will work with you to create the right solutions for you whether you want to save regularly or have existing investments for review. Alternatively, if you wish to invest in behalf of your children, grandchildren or via a trust we can arrange that for you too.
If you are just starting out in your career we can help you decide which type of pension is just right for you and work out how much you can afford to invest on a regular basis to achieve the kind of retirement you want.
However, if you have moved jobs a few times already and have several different pension plans with a number of providers we can review how well your pension plans are performing and determine if they will in fact meet your needs. If your pension is not meeting expectations or you have a number of small pension pots we can advise you as to whether combining your pensions under one provider would be suitable for you.
At Retirement Planning
We are on hand to help you make the right decisions when you are nearing retirement. We can offer advice on the different ways of taking an income from your existing plans and maximising your finances in retirement.
No matter what your net worth, it is important to have a basic estate plan in place. Such a plan ensures that your assets are passed on according to your wishes and that your loved ones are adequately provided for. When assessing your assets we include property, investments, retirement savings, insurance policies and business interests.
We also offer access to a specialist will writing service if needed.
If you need advice for your business then we are happy to discuss group pensions and employee benefits with you as well as personal and corporate services for company directors. Consideration will be given to key person, partnership and shareholder insurances for partnerships and limited companies. Our advisers will discuss your needs directly with you to ensure that you are adequately covered.
Whether you are reviewing your life insurance provision, protecting your income or considering critical illness cover we can help you find the right type of policy for you and your family to suit both your needs and your budget.
Tax Efficient Savings
When we assess your overall financial position, one of the key elements of that assessment will be to ensure that your arrangements are tax efficient. Our advice will take into account capital gains tax, income tax and inheritance tax where appropriate.
Long Term Care
If you, or a relative, need to consider residential or nursing care, our qualified advisers can guide you through the options available and working with both the care provider in question as well as the local authority, provide you with the solution best suited to your needs.
Our Advice Process
At Castle Sundborn we have a wealth of experience and market knowledge to help you get the most from your finances. We use a tried and tested approach to ensure that we manage all of our clients’ financial affairs efficiently, responsibly and ethically. This involves the following:
This is a ‘no obligation- no cost’ meeting which involves an initial discussion to identify your needs, your financial goals and your priorities.
How We Charge for Our Services
We offer a transparent and fair charging system for the advice and services we give. We will agree with you in advance how much you will pay for the work we undertake on your behalf, for any investments you make and for the ongoing advice and service we provide. Our Service Level Agreement towards the end of this document provides full details of the fees we charge for any initial advice and ongoing service. We will tell you if you have to pay VAT.
Review of Your Needs
Our advice process begins once you have instructed us to act on your behalf. As part of this process we will review:
- Your current financial circumstances
- What money you have coming in together with your average expenditure and what you need to keep in reserve
- Personal details about you and your family, your tax position and employment, your financial needs, future plans and Investment goals.
- Whether you require capital growth from your investments, income or both.
- Your existing investments will be reviewed to make sure they are still suitable for your needs.
Assessing Your Capacity for Risk/Loss
This is a very important area to be assessed and can vary from client to client. To enable us to ensure that our recommendations are suitable for you we will ask you a number of questions to do with how you view risk and how much risk you have taken with past investments. This will help us to agree on the amount of risk you are happy to take with any future investments.
We will advise and make a recommendation for you after we have assessed your needs. We only offer advice on limited types of products. You may ask us for a list of the products we offer. Any recommendations we make will be confirmed to you in writing and will show why we believe they are suitable for you. They will be based on your stated objectives and circumstances and take into account any restrictions that you wish to place on the type of products you would be willing to consider. They will include any associated risks and the costs of our advice. Full details of any products we may recommend to you including for example the minimum duration of the product, information on the right to cancel or whether no right to cancel arises and any other early termination rights and penalties will be covered in the relevant product disclosure information you will receive before conclusion of any contract.
When we have agreed how to proceed, we will implement the recommendations on your behalf.
Ongoing Review (where selected)
As a valued client of Castle Sundborn Ltd you will have:
- Continued access to an adviser
- Regular portfolio reviews
- A comprehensive review of your financial strategy
- Regular contact from us to ensure that any changes to your lifestyle or financial goals are reflected in your portfolio.
Our Promises to Our Clients
We value the reputation that we have earned over the years and we adhere to our code of ethics to maintain our professional standards and integrity at all times. This is confirmed in our pledges:
All Castle Sundborn advisers hold the required qualifications to provide you with appropriate advice and undergo a continuous process of professional development. They have both applied for and received a Statement of Professional Standing from one of the FCA’s accredited bodies.
Castle Sundborn will always endeavour to provide you with the highest level of service possible. All communications, both verbal and in writing, will be in English
A Castle Sundborn adviser will always recommend a course of action based on your specific circumstances and the needs that have been identified.
Referrals to Third Parties
There may be occasions whereby we would refer you to a specialist for specific advice such as tax advice. Should you pursue our suggestion to use the third party introduced to you, you should note that we are NOT responsible for the advice they give you. You will be subject to their terms and conditions. They will agree their charges for their advice direct with you.
Our Terms of Business
Who Regulates Us?
Castle Sundborn Ltd, The Old Bank, 10 High Street, Malmesbury, Wiltshire, SN16 9AU is authorised and regulated by the Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN. Our FCA Register number is 125913.
Our permitted business is advising on and arranging pensions, savings and investment products, mortgages and non-investment insurance contracts.
You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768.
Unless we notify you in writing to the contrary you will be treated as a ‘retail’ client for investment and pension advice and as a 'consumer' for protection advice. This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service. You may also be entitled to benefit from the maximum protection available under the Financial Services Compensation Scheme. The company and its representatives are not qualified to provide any legal advice and will not provide any opinion as to whether a client should complain about any previous advice received unless explicitly agreed.
We have a written policy for handling complaints and how we ensure we deal with each complaint promptly and fairly. You can obtain a summary from us should you so request. Should you have cause to complain for any reason a copy of our policy for handling complaints will be automatically sent to you.
If you should wish to register a complaint please contact:
The Compliance Officer, Castle Sundborn Ltd, The Old Bank, 10 High Street, Malmesbury, Wiltshire, SN16 9AU.
Telephone: Anthony Bather 01666 825200
A copy of our complaints procedure can be obtained from the above address.
If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service who can be contacted via their online enquiry form on their website address of www.financial-ombudsman.org.uk/ or alternatively by phone 0800 023 4567.
Castle Sundborn Ltd is permitted to handle client money for the purposes of General Insurance only. For all other types of business Castle Sundborn will not accept a cheque made out to us (unless it is in respect of an item for which we have sent you an invoice) or handle cash. This means that all investment monies will be made payable to the product provider recommended.
Conflict of Interest
We will endeavour to always act in the best interests of our clients. However, there may be occasions where we, or one of our customers, will have some form of interest in business that we are transacting for you. If this happens, or we become aware that our interests or those of one of our other customers conflict with your interests, we will inform you in writing and obtain your consent before we carry out your instructions. If we can continue to act for you, we will tell you how we will ensure your interests are protected. On occasions we may have to cease acting for you, but we will help you find advice from elsewhere if you want us to. Should you require further information in relation to our conflicts of interest policy then please contact us at the address shown.
In executing or transmitting orders on your behalf to third parties we will take all reasonable steps to ensure that we obtain the best post possible result for you in terms of best execution.
Please be aware that investments can fall as well as rise and that you may not get back the full amount invested. The price of investments we recommend may depend on fluctuations in the financial markets or other economic factors which are outside our control.
Non- readily realisable investments will generally have a restricted market and therefore it may be difficult to deal in that investment or obtain reliable information about its value. Levels of income from investments may fluctuate.
We cannot be held liable for any depreciation in the value of investments arranged for you except where you suffer loss as a result of wilful negligence on our part. Past performance is not necessarily a reliable indicator of future returns.
Specific risk warnings relevant to the investments or investment strategies we recommend will be confirmed to you in writing.
In most cases you can exercise a right to cancel, by withdrawing from the contract recommended to you. In general terms you will normally have a 30 day cancellation period for a life, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies. In most instances, you will not be able to exercise a right to cancel a mortgage contract, unless the contract is concluded at a distance (i.e. no face to face advice), at which point you may have a 14 day cancellation period.
The start of the cancellation period will normally begin, for pure protection policies, when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.
If you cancel a single premium contract, we may require you to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
We will endeavour to make arrangements for all your investments to be registered in your name unless you first instruct us otherwise in writing. All Policy Documents or Lender’s Offer Documents will be forwarded to you as soon as practicable after we receive them. If there are a number of documents relating to a series of transactions, we will normally hold each document until the series is complete and then forward them to you.
You or we may terminate our authority to act on your behalf at any time, without penalty. Notice of this termination must be given in writing and will take effect seven days from the date of receipt. Termination is without prejudice to any transactions already initiated which will be completed according to this Client Proposition unless otherwise agreed in writing. You will be liable to pay for any transactions made prior to termination and any fees outstanding, if applicable.
These Terms of Business are governed and shall be construed in accordance with English law and the parties shall submit to the exclusive jurisdiction of the English Courts.
Foreign Account Tax Compliance Act (FATCA)
The Foreign Account Tax Compliance Act (FATCA) requires US persons holding an interest in any specified foreign financial assets with an aggregate value exceeding $50,000 to report related information to the IRS. It is your responsibility to inform us if you:-
- Have US citizenship or lawful permanent resident (green card) status
- Born in the US
- Have a US residence address or US correspondence address (including a US PO box)
- Standing instructions to transfer funds to an account maintained in the United States or directions regularly received from a US address
- Have a ‘in care of’ address or a ‘hold mail’ address that is the sole address with respect to the client;
- Have a power of attorney or signatory authority granted to a person with a US address
Please note that we are not responsible in any way for any reporting obligations that you may have in relation to FATCA. We may also share your FATCA status with other Financial Institutions, HMRC and/or the IRS if requested’.
Are We Covered by the Financial Services Compensation Scheme (FSCS)?
We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.
Most types of investment business are covered for 100% of the first £85,000.
Cover for compulsory insurance is 100% of the claim with no upper limit. This also applies to pure protection policy claims arising from death or incapacity of the policy holder, such as life assurance, and any benefits falling due in the form of income such as annuity contracts.
For other non-compulsory insurances, the cover is 90% of the claim, with no upper limit.
Mortgage advising and arranging is covered for 100% of the first £85,000.
Further information about compensation scheme arrangements is available from the FSCS.
Our Service Level Agreement
An initial, one off fee is charged based on the value of any new funds or investments, including pensions.
|Service Feature||Amount of Initial Fee|
|Investments up to £100,000||Up to a maximum of 3% of the amount invested (minimum fee of £500 applies)|
|Investments between £100,001- £500,000||Up to a maximum of 2.5% of the amount invested|
|Investments between £500,001-£1,000,000||Up to a maximum of 2 % of the amount invested|
|Investments of more than £1,000,001||Upon agreement|
|Putting existing policies into trust||Up to £1,000 but to be agreed individually|
|Dealing with a death claim||Up to £1,000 but to be agreed individually|
|One off research projects||Fee to be agreed individually|
|Arranging protection policies||Commission paid by the provider (minimum fee of £500 applies).|
Our charges may increase if the service involves complex trust work.
- If you invest £10,000 into a collective investment, such as unit trusts we will charge a fee of up to £300 which is equivalent to 3% of the amount invested.
- If you invest £250,000 into a number of investments we will charge a fee of up to £6250 which is equivalent to 2.5% of the amount invested.
- If you invest £700,000 into a number of investments we will charge a fee of up to £14,000 which is equivalent to 2% of the amount invested.
There will be an additional charge for any ongoing work, such as periodic or ongoing reviews, you may wish us to carry out on your behalf. We will confirm the rate, frequency and length of this ongoing service before beginning any such service. An agreement of this type will automatically become suspended on your death.
If it is determined that a regular premium pension or investment policy is appropriate for you we will charge up to 50% of the first year’s annual premium as a fee subject to a minimum charge of £500 and up to 1% of the funds under management (FUM) to assist with the ongoing service etc.
The appendix ‘Our Client Service Proposition and Fee Agreement’ explains this in more detail.
We do offer the choice of paying for our services with an hourly rate but this does tend to be more suited to complex cases, typically Inheritance Tax Planning, Tax Reviews and Trust Work. It is difficult to estimate the number of hours that each provision is likely to require but we will review this on a case by case basis. You may ask us for an estimate of how much in total we might charge in your specific circumstances. You may also ask us not to exceed a given amount without checking with you first.
Our typical charges are:
Principal/Director £200-£250 per hour
Financial Adviser £150-£200 per hour
Administration £50 per hour
An example of charges for setting up a bare trust would be:-
Financial Adviser 2 hours @ £175 per hour = £350
Administration 1 hour @ £50 per hour = £50
These fees may be subject to VAT.
Settling your Adviser Charge in a Single Payment
All fees will be agreed with you and confirmed in writing before we proceed. Whether you buy a product from us or not, you will pay us an adviser charge for our advice and services. This will become payable on completion of our work. Fees become payable immediately on receipt by you of the relevant invoice and we reserve the right to produce an interim bill should the work involved require this. We reserve the right to charge interest of any sums not paid within 30 days of a due date: such interest to be at a rate equivalent to the base rate charged by HSBC Bank plc at the due date, plus 3%. You will be provided with a receipt upon payment.
If you buy a financial product, you can choose to have the adviser charge deducted from the product as a single payment. Although you pay nothing to us directly, that does not mean our service is free, you still pay us indirectly through a deduction from the amount you pay into your product. This deduction will settle the adviser charge. It will also reduce the amount directly invested.
Research & Administration
Castle Sundborn Ltd
The Old Bank
10 High Street
Tel: 01666 825200